It is common for multinational enterprises around the world to finance their associated subsidiaries in high-level tax jurisdictions through issuing debts rather than equities.
Introduction - The ever growing number of transactions involving MNEs over the past decade has resulted in transfer pricing becoming increasingly important. From the perspective of an MNE, transfer pricing offers the possibility to shift profits to affiliates located in low-tax jurisdictions. From the perspective of the tax authorities, profit shifting directly impacts on tax revenue meaning that appropriate countermeasures are necessary. Apart from that the tax authorities are becoming increasingly aware of the fact that transfer pricing adjustments can be a significant revenue booster. This ultimately leads to an increasing number of quite aggressive transfer pricing audits.
The term cloud is used by the information and communication technologies (ICT) industry to indicate, primarily, virtual platforms or infrastructures that allow the execution of codes (services, applications, among others) in various forms across multiple resources, with relevant data.
In this final part, Peter Wilson concludes his discussion of Article 12. Parts 1-3 appeared in the previous three issues of ITR.
The Russian government has joined the ranks of a great number of other jurisdictions which are seeking to introduce mandatory reporting requirements on the unreported capital of its citizens, placed, until now, in offshore locations. With large potential sums of tax revenue at stake, Russia’s Ministry of Finance has invested a lot of time and energy in considering ways to tighten reporting, to impose penalties on taxpayers who do not disclose their involvement in foreign entities and, more generally, to discourage the usage of offshore jurisdictions.
In Part I, Gabriel Magalhães Borges Prata examined Brazil’s thin capitalisation regime. He concludes this discussion here.
In Part I, Angelica Maria Orozco Diaz analysed the Intergovernmental Agreement between the USA and the UK in relation to FATCA. She continues her discussion here.
The Organisation for Economic Co-operation and Development (OECD)’s Base Erosion and Profit Shifting (BEPS) project has been creating considerable debate and discussion in the international tax community.
Investment and Indirect Taxes
In Part I, Sylvia H. Torres Caro discussed how Colombia attracts foreign investment and focused her discussion on legal stability agreements put in place by Colombia and other Latin American countries. She concluded by briefly discussing the role played by Colombia’s double tax treaties in securing foreign direct investment. Part II continues this discussion.
In Parts 1 and 2, which appeared in the March and April issues, Maria Cecilia Rossi discussed Cloud Computing and its interaction with the concept of permanent establishment. Here, in Part 3, she concludes her discussion.
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